Privacy Policy Deusverb Solutions Ltd · Company No. 17446360 · Incorporated 8 September 2026 Registered office: Bartle House, 9 Oxford Court, Manchester, M2 3WQ Last updated: September 2026 1. Who We Are Deusverb Solutions Ltd ("we", "us", "our") provides AI-powered lead engagement and follow-up services to businesses ("Clients") in the UK. This Policy explains how we collect, use, and protect personal data in two distinct roles: - As a data controller — for data relating to visitors of our own website, and to our own Clients. - As a data processor — for the personal data of leads and customers that our Clients instruct us to contact on their behalf. We are registered in England and Wales under company number 17446360, with a registered office at Bartle House, 9 Oxford Court, Manchester, M2 3WQ. We are not yet registered with the Information Commissioner's Office; our registration number will be added here once that process is complete. If you have questions about this Policy, contact us at [email protected]. 2. Scope of This Policy This Policy covers personal data we collect directly through our website, and personal data we process on behalf of our Clients as part of delivering our Services. If you are a lead or customer of one of our Clients and have received a message as part of an automated outreach campaign, the Client is the controller of your data and the appropriate party to contact with data subject requests in the first instance, per Section 8. We process that data strictly on their documented instructions. 3. What Personal Data We Collect From our own website visitors and Clients: - Contact details (name, email, phone number, company name) submitted via forms, booking tools, or email. - Technical data (IP address, browser type, device information, pages visited) collected via cookies — see Section 9. - Communications you send us directly. Processed on behalf of Clients (as processor), determined by the Client: - Name and contact details of the Client's leads or customers. - Prior enquiry or purchase context provided by the Client to make outreach relevant. - Message content and reply history generated during an automated conversation. We do not knowingly collect special category data (health, financial, biometric, etc.) as part of standard campaigns unless specifically instructed and contractually agreed with a Client, with appropriate safeguards in place. 4. How We Use Personal Data Purpose — Legal basis (UK GDPR) - Responding to enquiries via our website — Legitimate interests / pre-contractual steps - Delivering AI-powered outreach on behalf of a Client — Determined by the Client as controller - Managing our contractual relationship with Clients — Performance of a contract - Complying with legal or regulatory obligations — Legal obligation - Improving our Services — Legitimate interests Where we act as a processor, we do not use Client-supplied contact data for our own marketing purposes, and do not combine it with data from other Clients. 5. Automated Messaging & Consent Outreach campaigns we run on behalf of Clients are subject to PECR as well as UK GDPR: - Our Clients are responsible for ensuring they have a valid legal basis before instructing us to contact an individual. - Every message sent as part of a campaign includes a clear way to opt out (e.g. replying "STOP"). - Opt-out requests are actioned promptly, and the contact is suppressed from further outreach on that campaign. - We do not sell, rent, or share contact lists between Clients or with third parties for their own marketing purposes. 6. AI Processing Our Services use AI models to generate conversational responses as part of outreach and follow-up: - Message content may be processed by third-party AI infrastructure providers, including OpenAI. We may also use other AI providers from time to time to deliver the Services, always in keeping with our contractual terms and applicable international data protection law. - We take reasonable steps to ensure these providers offer appropriate data protection guarantees (UK/EU data processing terms, encryption in transit and at rest). - Individuals interacting with an AI-driven conversation are informed that they are speaking with an automated system at the earliest possible point of contact, and this will always be disclosed if directly asked. 7. Data Sharing We may share personal data with: - Sub-processors who support delivery of the Services (e.g. messaging gateways, hosting, AI providers). A current list is available on request by emailing [email protected]. - Our Clients, where the data relates to their own leads or customers and we are returning campaign results to them. - Regulators or authorities, where required by law. We do not sell personal data. 8. Data Subject Rights Under UK GDPR, individuals have the right to access, correct, or request erasure of their personal data, object to or restrict certain processing, request data portability where applicable, and lodge a complaint with the ICO (ico.org.uk). If you received a message as part of a campaign run by one of our Clients, please contact that business directly in the first instance, as they are the data controller. If you're unsure who to contact, reach out to us at [email protected] and we will direct your request appropriately. If your enquiry relates to our own website or our direct relationship with you as a Client, contact us directly at [email protected]. 9. Cookies [To be confirmed once the live site's actual cookie usage is known.] Our website may use cookies and similar technologies to enable core site functionality, understand aggregate visitor behaviour (analytics), and support advertising or retargeting where used. You can control cookie preferences through your browser settings or via our cookie consent tool, where applicable. 10. Data Retention - Website enquiry data is retained for up to 24 months unless a longer period is required for legal or contractual reasons. - Data processed on behalf of Clients is retained for the duration of the campaign, and for up to 6 years afterwards where required for legal, accounting, or tax purposes. 11. Data Security We implement technical and organisational measures appropriate to the risk, including encryption of data in transit (TLS), access controls limiting data access to personnel who need it, and regular review of sub-processor security practices. In the event of a personal data breach that poses a risk to individuals, we will notify affected Clients without undue delay, and will notify the ICO directly where we are acting as controller and the breach meets the statutory threshold. 12. Changes to This Policy We may update this Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page will indicate the most recent revision. 13. Contact Us Deusverb Solutions Ltd Website: www.deusverbsolutions.com Email: [email protected] Registered office: Bartle House, 9 Oxford Court, Manchester, M2 3WQ Company No.: 17446360 If you are not satisfied with our response to a data protection query, you have the right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk.